Constitutional Law; Free Exercise Clause; Whether a Parochial School
Principal's Action Against the Archdiocese of Hartford was Barred by the
"Ministerial Exception" to Judicial Authority. The plaintiff
served as the principal of a parochial school that was run by the Archdiocese
of Hartford. After the archdiocese declined to renew her employment contract,
the plaintiff initiated the present action against the archdiocese and the
pastor of the school, alleging, among other things, that her employment was
terminated because she had refused to retaliate against a student who had
asserted that the pastor had made inappropriate remarks during a religious
education class that he taught. The defendants filed a motion to dismiss the
action, claiming that the trial court lacked subject matter jurisdiction
pursuant to the free exercise clause of the first amendment to the United States constitution. In doing so, they invoked the "ministerial
exception" to judicial authority, which precludes courts from adjudicating
employment disputes between religious institutions and their religious leaders.
In denying the motion, the trial court determined that the plaintiff's claims
involved discrete inquiries that would not intrude upon purely religious
matters or issues relating to church governance. It reasoned that the
plaintiff's common-law contract and tort claims merely alleged, among other
things, that (1) the plaintiff was denied her contractual right under the
policies of the Office of Catholic Education to address her purported
performance deficiencies and cure them in a timely manner; and (2) her
employment was terminated as a result of her failure to "stick up
for" the school's pastor in connection with the controversy concerning his
allegedly inappropriate remarks. The resolution of these claims, the court
opined, would not require any intrusion into religious doctrine or practices.
In this appeal, the defendants argue that because the plaintiff was a
ministerial employee of the school in that she was important to the religious
mission of the church, the trial court lacked jurisdiction over her lawsuit
regardless of whether her specific claims implicated matters of religion. They
also contend, among other things, that the plaintiff's claims did, in fact, involve
religious practices and church governance.